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Q&As refer to the provisions in force on the day of their publication. The EBA does not systematically review published Q&As following the amendment of legislative acts. Users of the Q&A tool should therefore check the date of publication of the Q&A and whether the provisions referred to in the answer remain the same.

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List of Q&A's

Instructions to follow regarding new EBA Resolution Reporting - Z 09.02

The key values ​​of the templates are c0010 (ID representing the combination of user, FMI, system type, and intermediary), c0030 (Country), and c0040 (Critical Function ID). The c0060 "Core Business Line ID" is not set as a key. However, this does not allow for granular representation of multiple business lines associated with the same FMI–Critical Function combination. As communicated to us by our national authority, the EBA will not be providing a hotfix for DPM 4.2, and therefore the bank will adhere to the technical constraints imposed by the current technical documentation.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Technical problem due to validation

The current validation logic effectively forces the submission of an incomplete and therefore factually incorrect report, as only one participation can be reported per investor. We kindly ask you to review this issue and inform us promptly how institutions should proceed in this case. Please confirm whether an adjustment of the validation rule is planned or whether there is an alternative approach to correctly reflect our group structure.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Reporting of intragroup transactions in templates Z 07.01.1, Z 07.01.2, Z 07.01.3, Z 07.01.4 and Z 07.01.5

We kindly ask for clarification on the intragroup transactions reporting in the context of the criticality assessment of economic functions. Should the intragroup transactions be included or excluded from the data provided in templates Z 07.01.1, Z 07.01.2, Z 07.01.3, Z 07.01.4 and Z 07.01.5 ?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Erroneous configuration Z 07.01.2 FUNC 1 LEN

Given the absence of any specified time bands for the “Lending” template in the Annex, it appears likely that this may be due to an erroneous configuration. In this context, we respectfully request the EBA to review the matter and provide guidance at your earliest convenience regarding the appropriate procedure for institutions in this case.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Validation in Z_01.02

According to the EBA instructions for validating Template Z 01_02 (source: DPM table layout and data point categorization), the validation key for this template is the code in column 0020 (expected to be unique). This is the investor code (also with validation on number of characters), which may actually have more than one investment within the group (as is the case with our bank). The existing validation rule prevents correct reporting. Please provide instructions on how to proceed with this template.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

The question pertains to resolution template Z.07.01, in which deposits are evaluated to determine whether they should be classified as a CEF.

In column 0035 of template Z.07.01, where the amount of uncovered deposits must be reported, should the amount provided be the portion exceeding €100,000 per deposit, or the portion exceeding €100,000 per depositor?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

ESG P3 - Template 1 - validation rule v89257_m

Is the validation rules v89257_m correctly defined?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Z0200 - templates that should be reported on an individual basis

Regarding the templates that should be reported on an individual basis, for itself and for each relevant legal entity in the group (for example, the information specified in template Z 02.00 that should be reported according to the art. 4 letter (b) of CIR 2025/2303), the question is: Can the bank include also in its individual resolution report templates Z 02.00 for each relevant legal entity in the group or the relevant legal entities have to report the templates on an individual basis for themselves? If the bank can include also in its individual resolution report templates Z 02.00 for each relevant legal entity in the group, how can this be done from a technical point of view?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Article 2.2 Reporting by credit institutions permanently affiliated to a central body

In a particular case of an atypical structure of credit institutions permanently affiliated to a central body when: a) none of them is a resolution entity and the central body is a liquidation entity b) the cohort of institutions does not formally qualify as a group nor as a resolution group due to their atypical association c) the cohort is prudentially supervised individually at the level of the central body and in aggregate at the cohort level (our regulations use the term aggregate level, not the consolidated level) d) in case that the central body is liquidated, the whole cohort can no longer function and has to be dissolved, thus, for resolution purposes, the whole construction can be treated as a single liquidation entity.       In this case, is it correct, to read art. 2.2 in conjunction with recital no. 4 and ask the central body to report the templates on an individual basis and by that understand the aggregate level of the whole cohort?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Z 07.01.1 to Z 07.01.5 consolidated reporting

Regarding the templates Z 07.01.1 to Z 07.01.5 that should be reported for each Member State in which the group is active (as specified in Annex 1 to the regulation mentioned above), the question is: Could you please confirm if the bank can include separate templates for each country in a single individual resolution report?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Completion of Z08.x Templates

Does the “Unique service title” in Column 0020 of Z08.01 need to be unique to every contract i.e, if we have 150 different contracts should we have 150 different “Unique service titles” or can we have multiple contracts sharing the same service title? If we can have multiple contracts sharing the same “Unique service title”, should the “Service identifier” in column 0005 of Z08.01 be the same for each contract having a particular “Unique service title”? In Z08.01 can we assign multiple “Unique service titles” (Column 0020) and multiple “Service types” (Column 0010) to the same contract? In Z08.02 should the “Asset identifier” in Column 0030 be unique to each asset or to each contract? By way of example, if we have two contracts for leasing of two different premises, should we assign them the same asset identifier or a different one? In Z08.02 Column 0120, should contracts which require us to pay for the service in advance be considered to have an “Alternative mitigating action”? In Z08.03 Column 0030, if we have the same role name (e.g. “analyst”) across multiple departments should that role have the same “Role ID” across all departments or should we assign one ID per department? In Z08.03 Column 0060, should the “Criticality” value be the same as that in Column 0120 of Z08.01? If contracts can share a “Unique service title” (column 0020 of Z08.01) and the “Service identifier” (column 0005 of Z08.01) should be the same for the same service title, does that mean that each row in Z08.03 can represent multiple contracts? In Z08.03 can we assign multiple roles to the same contract? If contracts can share a “Unique service title” (column 0020 of Z08.01) and the “Service identifier” (column 0005 of Z08.01) should be the same for the same service title, does that mean that each row in Z08.04 can represent multiple contracts? In Z08.04, can we assign multiple critical functions (Columns 0030 and 0040) to the same contract? If contracts can share a “Unique service title” (column 0020 of Z08.01) and the “Service identifier” (column 0005 of Z08.01) should be the same for the same service title, does that mean that each row in Z08.05 can represent multiple contracts? In Z08.05 can we assign multiple core business lines (Column 0030) to the same contract?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Reporting of deposits fully secured by collateral with a value of zero

In which row of the Z02.00 template of the ‘Resolution Planning’ reporting, and in which granular template (Z13.00 or Z16.00), should deposits fully secured by collateral with a value of zero be reported? It should be noted that these exposures are not eligible for bail-in.  

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Inconsistencies between ITS on resolution planning reporting versus Annotated Table Layout DPM 4.2, RESOL1 and RESOL2

Could you please align the technical requirements stated in the Annotated Table Layout in the DPM 4.2 module (20260106 Annotated Table Layout RES 4.2 RESOL1RES 4.2.xls) with the requirements as stated in the ITS (Annex II: Instructions) on Z11.00, column 0060 Governing Law (as well in Z12.00 column 0070, Z13.00 column 005, Z14.00 column 0070, Z15.00 column 0100, Z08.01 column 0140, Z08.02 column 0090, Z09.01 column 0130)? 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Inconsistencies between ITS on resolution planning reporting versus Annotated Table Layout DPM 4.2, RESOL1 and RESOL2

Could you please align the technical requirements stated in the Annotated Table Layout in the DPM 4.2 module (20260106 Annotated Table Layout RES 4.2 RESOL1RES 4.2.xls) with the requirements as stated in the ITS (Annex II: Instructions) on Z11.00, column 0100 Currency (as well in Z12.00 column 0090, Z13.00 column 0060, Z14.00 column 0120, Z17.00 column 0100, Z09.01 columns 0150-0200)? 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Inconsistencies between ITS on resolution planning reporting versus Annotated Table Layout DPM 4.2, RESOL1 and RESOL2

Could you please align the technical requirements stated in the Annotated Table Layout in the DPM 4.2 module (20260106 Annotated Table Layout RES 4.2 RESOL1RES 4.2.xls) with the requirements as stated in the ITS (Annex II: Instructions) on Z05.01/Z05.02, column 0040 Country? 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Inconsistencies between ITS on resolution planning reporting versus Annotated Table Layout DPM 4.2, RESOL1 and RESOL2

Could you please align the technical requirements stated in the Annotated Table Layout in the DPM 4.2 module (20260106 Annotated Table Layout RES 4.2 RESOL2RES 4.2.xls) with the requirements as stated in the ITS (Annex II: Instructions) on Z08.01, column 0010 Service Type? 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Inconsistencies between ITS on resolution planning reporting versus Annotated Table Layout DPM 4.2, RESOL1 and RESOL2

Could you please align the technical requirements stated in the Annotated Table Layout in the DPM 4.2 module (20260106 Annotated Table Layout RES 4.2 RESOL1RES 4.2.xls) with the requirements as stated in the ITS (Annex II: Instructions) on Z01.01, column 0070 Article 7 CRR Waiver (and all other cells where ITS states the selection options Yes/No and the Annotated Table Layout states TRUE/FALSE instead)? 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

RESOL 1 - Z.01.02

Considering: 1) that the key of the Z.01.02 template is represented by field 20 only (investor code); 2) the template representation methods as regulated by the Annex of Reg. 2025/2303 require that field 20 be repeated across multiple records (for example: Investor 1 can hold more than n Investors). Therefore, it is necessary to replicate the aforementioned key. Given the absence of field 50 in the key, the template representation method is required.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Instructions to follow regarding new EBA Resolution Reporting

The Z_01.02 template of the RESOL1 survey, according to “Annex II – instructions”, should represent the situation of the shareholdings of the companies in a group, greater than 2%. The template requires that in the “code of Investor (c0020)” column we enter the code of the company that holds the participation, and in the “code of Investee (c0050)” column we enter the code of the company that is being participated. In some cases, the relationship between the two columns (Investor/Investee) is “1 to 1”: one Investor holds a participation in only one Investee. In other cases, the relationship between the two columns can be “1 to many”: one Investor holds participations in multiple Investees. However, in the annotated table layout of sheet Z_01.02, the only key value is indicated as “code of Investor – c0020” only, which therefore cannot be duplicated in the template in the situation where one investor holds participations in many investees. This rule does not allow us to correctly represent the information required by the template, because the case of a group company (investor) that holds participations in “n” other companies (investees) would violate the rule of the single key value (code of Investor – c0020). The filling of this template with exclusively the key value of column 0020, would give an incorrect representation of the requested data.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Z08 Report Submission Anomaly - Control on Fields 0030/0040 vs. 0050/0060

Is it possible to change or remove the two controls on fields 0030/0040 vs. 0050/0060?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting